Attachment DIRECTV - Grant Marc

DIRECTV - Grant Marc

DECISION submitted by IB,FCC

Grant

2014-03-12

This document pretains to SAT-MOD-20130718-00096 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2013071800096_1039352

                                                        y~ mxwrmemmnemsmmmenmenmencnnmmensmensont
                                                                                                    File# SAT—NMOD—20130718—0009%6
           SAT—MOD—20130718—00096       1B2013001576   I
$2861
DIRECTV Enterprises, LLC
DIRECTV KU—45W
                                                                                                    Call Sign $28Cl__       GrantDate 03112/14
                                                                                                    (or other identifier)
                                                                                                                            Term Dates                 Approved by OMB
                                                       |                                            From OBZIZEZ}L(               To:                         3060—0678
                                                       |
                                                                        bNdicabakdatibeire | Approved:
                                                       g         International Bureau
   Date & Time Filed: Jul 18 2013 5:04:11:446PM            ...
   File Number: SAT—MOD—20130718—00096                 #uwdth conditions                                               Ste           . Duall
                                                                                                                        Chief, Satellite FolicyBanch
        FCC APPLICATION FOR SPACE AND EARTH STATION:MOD OR AMD — MAIN FORM                                                        FCC Use Only

                           FCC 312 MAIN FORM FOR OFFICIAL USE ONLY


   APPLICANT INFORMATION
   Enter a description of this application to identify it on the main menu:
   SAT—MOD—KU—7IW
   1—8. Legal Name ofApplicant

              Name:        DIRECTV Enterprises, LLC                    Phone Number:                                         301—663—0053

              DBA                                                      Fax Number:                                           240—358—0569
              Name:

              Street:      2230 E. Imperial Hwy                        E—Mail:                                              jwengryniuk@directv.com
                           CA/LAI/N340
              City:        El Segundo                                  State:                                                CA
              Country:      USA                                        Zipcode:                                              90245       —
              Attention:   Mr Jack M Wengryniuk


                                           Attachment to Grant
                                    DIRECTV Enterprises, LLC
                              IBFS File No. SAT—MOD—20130718—00096
                                           Call Sign S$2861

The application of DIRECTV Enterprises, LLC (DIRECTV), IBFS File No. SAT—MOD—
20130718—00096, as supplemented," to modify the authorization for its DIRECTV KU—79W
geostationary—satellite orbit space station (Call Sign S$2861) is GRANTED. Accordingly,
DIRECTV is authorized to construct, launch, and operate DIRECTV KU—79W, as modified, to
provide Fixed—Satellite Service (FSS) in the 11.7—12.2 GHz (space—to—Earth) and 14.0—14.5 GHz
(Earth—to—space) frequency bands at the 78.8° W.L. orbital location instead of its previously
authorized 79.0° W.L. orbital position. DIRECTV is also authorized to conduct Telemetry,
Tracking, and Command (TT&C) functions necessary to operate DIRECTV KU—79W at the
78.8° W.L. orbital location using the following center frequencies: 11.704 GHz and 11.705 GHz
(space—to—Earth); and 14.005 GHz and 14.495 GHz (Earth—to—space). This authorization must be
in accordance with the technical specifications set forth in DIRECTV‘s application, as
supplemented, Federal Communication Commission rules not waived herein, and the following
conditions:

    1. Except to the extent modified herein, DIRECTV must operate DIRECTV KU—79W
pursuant to the terms and conditions contained in IBFS File No. SAT—LOA—20120316—00051, as
amended by IBFS File No. SAT—AMD—20120420—00071 (granted July 12, 2012).
    2. DIRECTV‘s request for a waiver of Section 25.210(i)(1) of the Commission‘s rules, 47
C.F.R. § 25.210(i)(1), is GRANTED. Section 25.210(i)(1) requires FSS space station antennas
to be designed to meet a cross—polarization isolation of 30 dB within the primary coverage area
of the antenna. The DIRECTV KU—79W antennas have been designed to meet a minimum
cross—polarization requirement of 27 dB. DIRECTV states that its cross—polarization interference
is an intra—system design issue that does not affect inter—system coordination and therefore will
not affect other Ku—band satellite systems, and that use of digital modulation with forward error
correction coding on both polarization senses reduces the system sensitivity to cross—polarization
interference. DIRECTV further states that polarization isolation, directivity and antenna
implementation losses have been jointly optimized to yield the best overall performance, and that
the expected level of cross—polarization isolation and resulting cross—polarization interference
accounts for a small fraction of the overall total link noise. DIRECTV also states that a
minimum isolation of 27 dB is more than sufficient to avoid excessive levels of intra—system
interference. This waiver is based upon a finding that this shortfall will not produce a significant
increase in interference, except to the space station itself, and will not adversely affect any other
operator. As a condition to the grant of this waiver, DIRECTV must claim no more protection
from interference from other licensed radio—communication systems operating in accordance
with the Commission‘s rules than if its antennas met Section 25.210(i) of the rules.
     3. DIRECTV‘s request for a waiver of Section 25.114(d)(3) of the Commission‘s rules, 47
C.FR. § 25.114(d)(3), and Item S8 of Schedule S, is GRANTED. Section 25.114(d)(3) requires
predicted space station antenna gain contour(s) for each transmit and each receive antenna beam


\ See Letter to Marlene H. Dortch, Secretary, F.C.C., from William M. Wiltshire, Counsel for DIRECTV
Enterprises, LLC (Sept. 9, 2013) (Sept. 2013 Letter); Letter from William M. Wiltshire, Counsel for DIRECTV
Enterprises, LLC, to Marlene H. Dortch, Secretary, Federal Communications Commission (Feb. 7, 2014)(Feb. 2014
Letter).


                                       Attachment to Grant
                                 DIRECTV Enterprises, LLC
                           IBFS File No. SAT—MOD—20130718—00096
                                        Call Sign $2861

and nominal orbital location requested. Item S8 of Schedule S calls for a .gxt file containing
antenna gain contour data for each beam on the spacecraft. DIRECTV states that the Schedule S
software was unable to accommodate the .gxt file for the global horn used for on—station TT&C,
but that antenna gain contours for this horn has been provided graphically in Appendix B to the
application, rather than as a .gxt file. Additionally, DIRECTV states that the beamwidth of the
horn antenna is very wide, and that there is little useful information gained by providing this
information in .gxt format. Section 25.114(d)(3) also calls for antenna gain contours to be
plotted on an area map at 2 dB intervals down to 10 dB and at 5 dB intervals between 10 dB and
20 dB below the peak values. DIRECTV states that it has provided the —2 dB, —4 dB, and —6 dB
gain contours for the TT&C global horn, however, any gain contour beyond —6 dB falls beyond
the visible Earth and cannot be depicted. We find that the information provided in Appendix B
and in Figure B—5 of Appendix B, together with the descriptive characterization provided on
page two of the waiver requests, fulfill the requirements of Section 25.114(d)(3).
    4. 17/24 GHz Broadcasting—Satellite Service (BSS) Capacity. DIRECTV is also granted
authority to construct and launch this space station with the capability of operating in the 24.75—
25.25 GHz (Earth—to—space) and 17.3—17.8 GHz (space—to—Earth) frequency bands. DIRECTV
has not sought and is not authorized to operate the 17/24 GHz BSS payload at the 78.8° W .L.
orbital location. Grant of construction and launch authority for this 17/24 GHz BSS capacity
does not convey to DIRECTV any status under the Commission‘s first—come, first—served
processing framework with respect to the 17/24 GHz BSS capacity on this satellite.
           a. Construction and launch of the satellite without obtaining operational authority
              for the 17/24 GHz BSS capacity is at DIRECTV‘s own risk.
           b.    Grant of authority to construct and launch the 17/24 GHz BSS payload is subject
                to the rules adopted in the Commission‘s rulemaking in IB Docket No. 06—123
                and any requirements subsequently adopted therein.
           c. DIRECTV‘s request for a partial waiver of the requirement to provide
                interference analyses, pursuant to Section 25.140(b) of the Commission‘s rules,
                47 C.F.R. § 25.140(b), is granted as conditioned. Section 25.140(b) requires an
                applicant for a 17/24 GHz network to demonstrate the compatibility of its
                proposed network with any current or future authorized 17/24 GHz BSS space
                station within four degrees of the applicant‘s proposed 17/24 GHz BSS space
                station. Because DIRECTV is not seeking operational authority for the 17/24
                GHz payload at this time, it did not provide an analysis tailored to a specific
                orbital location. DIRECTV did, however, submit a set of worst—case calculations,
                which show that the maximum PFD on the Earth‘s surface from the transmission
                in the 17 GHz frequency band is lower than the lowest value specified in the
                regional PFD limitations set forth in Section 25.208(w), and lower than the lowest
                values specified for the 17.7—17.8 GHz band in 25.208(c), of the Commission‘s
                rules. In view of these circumstances, we find that waiver would not undermine
                the policy objective of the rule and that requiring DIRECTV to provide the
                requisite interference analyses at this time, would not serve the public interest. If
                DIRECTV seeks operational authority for the 17/24 GHz payload, DIRECTV will


                                          Attachment to Grant
                                      DIRECTV Enterprises, LLC
                                IBFS File No. SAT—MOD—20130718—00096
                                             Call Sign $2861

                  be required to submit an interference analysis that is specific to the requested
                  orbital location, as required by the rule.
             d. DIRECTV‘s request for partial waiver of the requirement to provide predicted
                transmitting antenna off—axis gain information and associated PFD calculations
                  pursuant to Sections 25.264(a)—(b) of the Commission‘s rules, 47 C.F.R. §
                  25.264(a)—(b), is granted as conditioned. Sections 25.264(a)—(b) require each
                  applicant for a 17/24 GHz BSS space station license to submit with its application
                  predicted transmitting antenna off—axis gain information and associated power
                  flux density (PFD) calculations based on this information to show that its
                  proposed operations would not exceed the applicable coordination trigger at the
                  location of any prior—filed U.S. DBS space station. Sections 25.264(a)—(b) are
                  designed to mitigate the potential for space path interference to DBS operations.
                  Because DIRECTV is not seeking operational authority for the 17/24 GHz
                  payload at this time, it did not provide an analysis tailored to a specific orbital
                  location. Further, DIRECTV states that although it did not provide the predicted
                  transmitting antenna off—axis gain information required by the rule at this time, it
                  did submit a set of worst—case calculations demonstrating that for any orbital
                  separation of 0.077 degrees or greater, the satellite‘s far off—axis PFD is below the
                  coordination trigger established under the Commission‘s rules. DIRECTV further
                  committed to undertaking tests of the 17 GHz antenna prior to launch that are
                  necessary prerequisite to supplying measured transmitting antenna off—axis gain
                  information and associated PFD calculations required under other provisions of
                  Sections 25.264. In view of these circumstances, we find that waiver would not
                  undermine the policy objective of the rule and that requiring DIRECTV to
                  provide predicted transmitting antenna off—axis gain information and associated
                  PFD calculations at this time, would not serve the public interest. In the event
                  DIRECTV seeks operational authority for the 17/24 GHz payload, DIRECTV will
                  be required to fully comply with the information requirements of Section 25.264."
    5. DIRECTV is afforded thirty days from the date of release of this grant and authorization
to decline this authorization as conditioned. Failure to respond within this period will constitute
formal acceptance of the authorization as conditioned.
    6. This authorization is issued pursuant to Section 0.261 of the Commission‘s rules on
delegated authority, 47 C.F.R. § 0.261, and is effective upon release. Petitions for
reconsideration under Section 1.106 or applications for review under Section 1.115 of the



> This information will include the measured data and associated PFD calculations required by Sections 25.264(c)—
(d) and, depending upon when such a future application is filed, may also include the predicted data and associated
PFD calculations required by Sections 25.264(a)—(b). DIRECTV states that it understands that the present waiver
would not extend to the requirement for measured data and related calculations that would apply should DIRECTV
ever seek operational authority for this payload, and that in any case it fully intends to conduct such measurements
prior to launch of the space station. See Feb. 2014 Letter.


                                     Attachment to Grant
                                 DIRECTV Enterprises, LLC
                           IBFS File No. SAT—MOD—20130718—00096
                                        Call Sign S$2861

Commission‘s rules, 47 C.F.R. §§ 1.106, 1.115, may be filed within 30 days of the date of the
public notice indicating that this action was taken.




                                              Tile# GBT—MOD—20307)8— 00096

                                              Call Sign §$28(1        Grant Date o3hza/
                                              (or other identifier)
                                                                      Term Dates
                                     En       From OB[)Z[\'-%               To:

                                       reau   Approved:
                        & usthcondi hons


9—16. Name of Contact Representative

           Name:       William M. Wiltshire      Phone Number:   202—730—1301
           Company:    Wiltshire & Grannis LLP   Fax Number:     202—730—1301
           Street:     1200 18th Street NW       E—Mail:         WWiltshire@wiltshiregrannis.com


                       Suite 1200

          City:        Washington                State:          DC
           Country:     USA                      Zipcode:        20036—
          Attention:   William M. Wiltshire      Relationship:   Legal Counsel


CLASSIFICATION OF FILING


17. Choose the button next to the
classification that applies to this filing for   (N/A) b1. Application for License of New Station
both questions a. and b. Choose only one         (N/A) b2. Application for Registration of New Domestic Receive—Only Station
for 17a and only one for 17b.                    «3 b3. Amendment to a Pending Application
                                                  & b4. Modification of License or Registration
   «3 al. Earth Station
                                                 b5. Assignment of License or Registration
   @ a2 Space Station                            b6. Transfer of Control of License or Registration
                                                 3 b7. Notification of Minor Modification
                                                  (N/A) b8. Application for License of New Receive—Only Station Using Non—U.S. Licensed
                                                 Satellite
                                                  (N/A) b9. Letter of Intent to Use Non—U.S. Licensed Satellite to Provide Service in the United
                                                 States
                                                  (N/A) b10. Other (Please specify)
                                                    (N/A) b1 1. Application for Earth Station to Access a Non—U.S .satellite Not Currently Authorized
                                                 to Provide the Proposed Service in the Proposed Frequencies in the United States
                                                    (N/A) b12. Application for Database Entry
                                                  <34 b13. Amendment to a Pending Database Entry Application
                                                  g3 b14. Modification of Database Entry

 17c¢. Is a fee submitted with this application?
@ IfYes, complete and attach FCC Form 159.             If No, indicate reason for fee exemption (see 47 C.F.R.Section 1.1114).
q4 Governmental Entity        C Noncommercial educational licensee
C3 Other(please explain):

17d.

Fee Classification BFY — Space Station Modification(Geostationary)


 18. If this filing is in reference to an    19. If this filing is an amendment to a pending application enter both fields, if this filing is a
 existing station, enter:                    modification please enter only the file number:
 (a) Call sign of station:                   (a) Date pending application was filed:               (b) File number:
     $2861
                                                                                                   SATLOA2012031600051



TYPE OF SERVICE
20. NATURE OF SERVICE: This filing is for an authorization to provide or use the following type(s) of service(s): Select all that apply:

E a. Fixed Satellite
D b. Mobile Satellite
E] c. Radiodetermination Satellite
D d. Earth Exploration Satellite
E e. Direct to Home Fixed Satellite
D £. Digital Audio Radio Service
E] g. Other (please specify)


21. STATUS: Choose the button next to the applicable status. Choose        |22. If earth station applicant, check all that apply.
only one.                                                                  D Using U.S. licensed satellites
«3 Common Carrier            g Non—Common Carrier                          En Using Non—U.S. licensed satellites

23. If applicant is providng INTERNATIONAL COMMON CARRIER service, see instructions regarding Sec. 214 filings. Choose one. Are these
facilities:
g4 Connected to a Public Switched Network   «4 Not connected to a Public Switched Network g N/A


 24. FREQUENCY BAND(S): Place an ‘X" in the box(es) next to all applicable frequency band(s).
D a. C—Band (4/6 GHz) E b. Ku—Band (12/14 GHz)
D c.Other (Please specify upper and lower frequencies in MHz.)
        Frequency Lower:       Frequency Upper: (Please specify additional frequencies in an attachment)


TYPE OF STATION
25. CLASS OF STATION: Choose the button next to the class of station that applies. Choose only one.
4 a. Fixed Earth Station
«4 b. Temporary—Fixed Earth Station
«34 c. 12/14 GHz VSAT Network
«4 d. Mobile Earth Station
{&, e. Geostationary Space Station
o 6 Non—Geostationary Space Station
«4 g. Other (please specify)


26. TYPE OF EARTH STATION FACILITY:
«3 Transmit/Receive       gy Transmit—Only      gt4 Receive—Only     @ N/A
"For Space Station applications, select N/A."


PURPOSE OF MODIFICATION


27. The purpose of this proposed modification is to: (Place an °‘X" in the box(es) next to all that apply.)


    D a —— authorization to add new emission designator and related service
    D b — authorization to change emission designator and related service
    D c —— authorization to increase EIRP and EIRP density
    D d —— authorization to replace antenna
    D e —— authorization to add antenna
    L‘] f —authorization to relocate fixed station
    D g —— authorization to change frequency(ies)
     D h — authorization to add frequency
    D i —authorization to add Points of Communication (satellites &amp; countries)
    D j —— authorization to change Points of Communication (satellites &amp; countries)
        k — authorization for facilities for which environmental assessment and
radiation hazard reporting is required
     D 1 —— authorization to change orbit location
    E] m —— authorization to perform fleet management
    D n — authorization to extend milestones
    [g‘l o —— Other (Please specify)


ENVIRONMENTAL POLICY


 28. Would a Commission grant of any proposal in this application or amendment have a significant environmental        «y Yes @y No
 impact as defined by 47 CFR 1.1307? IfYES, submit the statement as required by Sections 1.1308 and 1.1311 of
 the Commission‘s rules, 47 C.F.R. 1.1308 and 1.1311, as an exhibit to this application.A Radiation Hazard Study
 must accompany all applications for new transmitting facilities, major modifications, or major amendments.



ALIEN OWNERSHIP Earth station applicants not proposing to provide broadcast, common carrier, aeronautical en route or
acronautical fixed radio station services are not required to respond to Items 30—34.


 29. Is the applicant a foreign government or the representative of any foreign government?                            4 Yes @ No




 30. Is the applicant an alien or the representative of an alien?                                                      4 Yes 4 No & N/A




31. Is the applicant a corporation organized under the laws of any foreign government?                                 ; Yes ; No & N/A




32. Is the applicant a corporation of which more than one—fifth of the capital stock is owned of record or voted by    4 Yes @4 No @ N/A
aliens or their representatives or by a foreign government or representative thereof or by any corporation organized
under the laws of a foreign country?


33. Is the applicant a corporation directly or indirectly controlled by any other corporation of which more than          o Yes { No &# N/A
one—fourth of the capital stock is owned of record or voted by aliens, their representatives, or by a foreign
government or representative thereof or by any corporation organized under the laws of a foreign country?




34. If any answer to questions 29, 30, 31, 32 and/or 33 is Yes, attach as an exhibit an identification of the aliens or
foreign entities, their nationality, their relationship to the applicant, and the percentage of stock they own or vote.



BASIC QUALIFICATIONS

35. Does the Applicant request any waivers or exemptions from any of the Commission‘s Rules?                                  @ Yes        gy No
IfYes, attach as an exhibit, copies of the requests for waivers or exceptions with supporting documents.

                                                                                                                          Waiver Request




36. Has the applicant or any party to this application or amendment had any FCC station authorization or license              4 Yes        @, No
revoked or had any application for an initial, modification or renewal of FCC station authorization, license, or
construction permit denied by the Commission? IfYes, attach as an exhibit, an explination of circumstances.


37. Has the applicant, or any party to this application or amendment, or any party directly or indirectly controlling    {y Yes   @ No
the applicant ever been convicted of a felony by any state or federal court? IfYes, attach as an exhibit, an
explination of circumstances.




38. Has any court finally adjudged the applicant, or any person directly or indirectly controlling the applicant,        y Yes    @ No
guilty of unlawfully monopolizing or attemptiing unlawfully to monopolize radio communication, directly or
indirectly, through control of manufacture or sale of radio apparatus, exclusive traffic arrangement or any other
means or unfair methods of competition?IfYes, attach as an exhibit, an explanation of circumstances




39. Is the applicant, or any person directly or indirectly controlling the applicant, currently a party in any pending   3 Yes    «y No
matter referred to in the preceding two items? If yes, attach as an exhinit, an explanation of the circumstances.




40. If the applicant is a corporation and is applying for a space station license, attach as an exhibit the names,
address, and citizenship of those stockholders owning a record and/or voting 10 percent or more of the Filer‘s
voting stock and the percentages so held. In the case of fiduciary control, indicate the beneficiary(ies) or class of
beneficiaries. Also list the names and addresses of the officers and directors of the Filer.


 41. By checking Yes, the undersigned certifies, that neither applicant nor any other party to the application is           CRG          £4 No
 subject to a denial of Federal benefits that includes FCC benefits pursuant to Section 5301 of the Anti—Drug Act of
 1988, 21 U.S.C. Section 862, because of a conviction for possession or distribution of a controlled substance. See
 47 CFR 1.2002(b) for the meaning of &quot;party to the application&quot; for these purposes.




42a. Does the applicant intend to use a non—U.S. licensed satellite to provide service in the United States? IfYes,         3 Yes        @ No
answer 42b and attach an exhibit providing the information specified in 47 C.F.R. 25.137, as appropriate. If No,
proceed to question 43.




42b. What administration has licensed or is in the process of licensing the space station? If no license will be issued, what administration has
coordinated or is in the process of coordinating the space station?




43. Description. (Summarize the nature of the application and the services to be provided).    (If the complete description does not appear in this
box, please go to the end of the form to view it in its entirety.)
     DIRECTV Enterprises,           LLC seeks minor modification of its license to operate a Ku—band
     satellite at the nominal 79 WL orbital location to reflect revised design and operating
     parameters.


Narrative




10


 43a. Geographic Service Rule Certification                                                                                    Cy A
 By selecting A, the undersigned certifies that the applicant is not subject to the geographic service or geographic
 coverage requirements specified in 47 C.F.R. Part 25.
                                                                                                                               @ B
 By selecting B, the undersigned certifies that the applicant is subject to the geographic service or geographic
 coverage requirements specified in 47 C.F.R. Part 25 and will comply with such requirements.
                                                                                                                               y C
 By selecting C, the undersigned certifies that the applicant is subject to the geographic service or geographic
 coverage requirements specified in 47 C.F.R. Part 25 and will not comply with such requirements because it is not
 feasible as a technical matter to do so, or that, while technically feasible, such services would require so many
 compromises in satellite design and operation as to make it economically unreasonable. A narrative description
 and technical analysis demonstrating this claim are attached.




CERTIFICATION
The Applicant waives any claim to the use of any particular frequency or of the electromagnetic spectrum as against the regulatory power of the
United States because of the previous use of the same, whether by license or otherwise, and requests an authorization in accordance with this
application. The applicant certifies that grant of this application would not cause the applicant to be in violation of the spectrum aggregation limit
in 47 CFR Part 20. All statements made in exhibits are a material part hereof and are incorporated herein as if set out in full in this application.
The undersigned, individually and for the applicant, hereby certifies that all statements made in this application and in all attached exhibits are
true, complete and correct to the best of his or her knowledge and belief, and are made in good faith.




11


44. Applicant is a (an): (Choose the button next to applicable response.)

 «3 Individual
 C Unincorporated Association
 {4 Partnership
 C Corporation
 C Governmental Entity
 @ Other (please specify)




     45. Name of Person Signing                                             46. Title of Person Signing
     Romulo Pontulo                                                         Executive Vice President
       ——>


             WILLEFUL FALSE STATEMENTS MADE ON THIS FORM ARE PUNISHABLE BY FINE AND / OR IMPRISONMENT
                      (U.S. Code, Title 18, Section 1001), AND/OR REVOCATION OF ANY STATION AUTHORIZATION
                    (U.S. Code, Title 47, Section 312(a)(1)), AND/OR FORFEITURE (U.S. Code, Title 47, Section 503).




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Document Created: 2014-03-13 12:44:58
Document Modified: 2014-03-13 12:44:58

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